ML20077F237
| ML20077F237 | |
| Person / Time | |
|---|---|
| Site: | Callaway, Cherokee  |
| Issue date: | 12/09/1994 |
| From: | UNION ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20077F235 | List: |
| References | |
| NUDOCS 9412130326 | |
| Download: ML20077F237 (21) | |
Text
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ATTACHMENT 1 TECHNICAL SPECIFICATION CHANGES (MARKED-UP)
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CONTAINMENT SYSTEMS SUR EltlANCE RE001REMENTS (Continued) i a.
Three Type A tests (Overall Integrated Containment Leakage Rate)
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shall be conducted at 40 1 10 month intervals
- during shutdown at a l
pressure not less than P,, 48.1 psig, during each 10-year service period.
b.
If'any periodic as found Type A test fails to meet L, the test schedule for subsequent Type A tests shall be review,ed and approved by the Commission.
If two consecutive as found Type A tests fail to meet L, a Type A test shall be performed at least every 18 months until two consecutive as found Type A tests meet L, at which time the above test schedule may be resumed. Theasleftoverall integrated containment leakage rate shall be less than 0.75 L,;
- A one-time extension of the test interval is allowed for the third Type A test of the first 10-year service period, provided unit shutdown occurs no later than Much 01, 1005-and performance of the Type A test occurs prior to unit restart following Refuel y AmendmentNo.73/II'77 CALLAWAY - UNIT 1 3/4 6-2a 4
3/4.6 CONTAINMENT SYSTEMS 1
BASES 3/4.6,1 PRIMARY CONTAINHENT 3/4.6.1.1 CONTAINMENT INTEGRITY Primary CONTAINMENT INTEGRITY ensures that the release of radioactive materials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the safety analyses. This restriction, in conjunction with the leakage rate limitation, will limit the SITE BOUNDARY radiation doses to within the dose guideline values of 10 CFR Part 100 during accident conditions.
3/4.6.1.2 CONTAINMENT LEAKAGE The limitations on containment leakage rates ensure that the total containment leakage volume will not exceed the value assumed in the accident analyses at the peak accident pressure, P. As an added conservatism, the measured overall integrated leakage rate,is further limited to less than or equal to 0.75 L, during performance of the periodic test to account for possible degradation of the containment leakage barriers between leakage tests.
The surveillance testing for measuring leakage rates are consistent with the requirements of Appendix J of 10 CFR Part 50.*
l The following exemptions have been granted to the requirements of Appendix J of 10 CFR Part 50:
1.
Section Ill.A.l(a) - an exemption to the requirement to stop the Type A test if excessive leakage is determined. This exemption allows the satisfactory completion of the Type A test if the leakage can be isolated and appropriately factored into the results.
2.
Section Ill.A.5(b) - an exemption for the acceptance criteria, in lieu of the present single criterion of the. total measured containment leakage rate being less than 0.75 of the maximum i
l allowable leakage rate, L, the "as found" allowable leakage rate and the "as left" allowable leakage rate will be less will be L,L,.
than 0.75
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3.
Section !!!.D.l(a) - an exemption that removes the requirement that the third test of each set of three Type A tests be conducted when j
the plant is shutdown for the 10-year plant inservice inspection.
- A one-time extension of the test interval is allowed for the third Type A
)
test of the first 10-year service period, as required by Surveillance Require-ment 4.6.1.2.a and by Section III.D.l.(a) of Appendix J to 10 CFR Part 50, provided unit shutdown occurs no later than Mrd
1, '005 and performance of the Type A test occurs prior to unit restart fol wing Refuel CALLAWAY - UNIT 1 B 3/4 6-1 Amendment No.7E.77
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0 ATTACHMENT 2 TECHNICAL SPECIFICATION CHANGES (RE-TYPED) 4
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CONTAINMENT SYSTEMS j
SURVEILLANCE REQUIREMENTS (Continued)
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a.
Three Type A tests (Overall Integrated Containment Leakage Rate) shall be conducted at 40110 month intervals
- during shutdown at a pressure not less than P,,48.1 psig, during each 10-year service period.
b.
If any periodic as found Type A test fails to meet L, the test schedule for a
subsequent Type A tests shall be reviewed and approved by the Commission.
If two consecutive as found Type A tests fail to meet L, a Type A test shall be performed at least every 18 months until two consecutive as found Type A tests meet L,, at which time the above test schedule may be resumed. The as left overall integrated containment leakage rate shall be less than 0.75 L ;
a A one-time extension of the test intervalis allowed for the third Type A test of the first 10-year service period, provided unit shutdown occurs no later than October 31,1996 and performance of the Type A test occurs prior to unit restart following Refuel 8.
CALLAWAY - UNIT 1 3/4 6-2a Amendment No. 78,75,77
3/4.6 CONTAINMENT SYSTEMS BASES l
3/4.6.1 PRIMARY CONTAINMENT 3/4.6.1.1 CONTAINMENT INTEGRITY Primary CONTAINMENT INTEGRITY ensures that the release of radioactive j
materials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the safety analyses. This restriction,in conjunction with the leakage rate limitation, will limit the SITE BOUNDARY radiation doses to within the dose guideline values of 10 CFR Part 100 during accident conditions.
3/4.6.1.2 CONTAINMENT LEAKAGE The limitations on containment leakage rates ensure that the total containment leakage volume will not exceed the value assumed in the accident analyses at the peak accident pressure, P,. As an added conservatism, the measured overall integrated leakage rate is further limited to less than or equal to 0.75 L, during performance of the periodic test to account for possible degradation of the containment leakage barriers between leakage tests.
The surveillance testing for measuring leakage rates are consistent with the requirements of Appendix J of 10 CFR Part 50."
The following exemptions have been granted to the requirements of Appendix J of 10 CFR Part 50:
1.
Section Ill.A.1(a) - an exemption to the requirement to stop the Type A test if excessive leakage is determined. This exemption allows the satisfactory completion of the Type A test if the leakage can be isolated and appropriately factored into the results.
2.
Section III.A.5(b) - an exemption for the acceptance criteria, in lieu of the present single criterion of the total measured containment leakage rate being less than 0.75 of the maximum allowable leakage rate, L, the "as found" a
allowable leakage rate will be L., and the "as left" allowable leakage rate will be less than 0.75 L,.
3.
Section Ill.D.1(a) - an exemption that removes the requirement that the third test of each set of three Type A tests be conducted when the plant is shutdown for the 10-year plant inservice inspection.
A one-time extension of the test intervalis allowed for the third Type A test of the first 10-year service period, as required by Surveillance Requirement 4.6.1.2.a and by Section Ill.D.1.(a) of Appendix J to 10 CFR Part 50, provided unit shutdown occurs no later than October 31,1996 and performance of the Type A test occurs prior to unit restart following Refuel 8.
CALLAWAY - UNIT 1 B 3/4 6-1 Amendment No. 75,77
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ATTACHMENT 3 SAFETY EVALUATION P
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Attachmsnt 3 Page 1.of 6 EAEETY EVALUATION
'This application requests an exemption to 10 CFR 50, Appendix J, Section III.D.1(a) and a revision to Technical Specification (TS) Surveillance Requirement 4.6.1.2.a and its associated Bases.
10 CFR 50, Appendix J and the Callaway TS j
require that a set of three Containment Integrated Leak Rate 1
Tests (CILRTs or Type A tests) be performed, at approximately equal intervals during each 10-year service period. 'This change consists of an exemption request and TS amendment that would defer the next scheduled CIIRT for one outage, from Refuel 7 (scheduled for March 1995) to Refuel 8 (scheduled for September 1996).
The preoperational CILRT was performed in January 1984.
The first and second CILRTs, of the set of three tests for the i
first ten-year service period, were conducted in April 1987 and October 1990, respectively.
This represents testing intervals of 40 and 41 months.
The third CILRT is required to be performed prior to restart following Refuel 7.
Deferring the third CILRT until Refuel 8 results in a test interval of approximately 72 months.
Exemption Reauest 10 CFR 50.12 states that the NRC may grant exemptions to its regulations in Part 50 if special circumstances exist.
Special circumstances are considered to exist if application of the regulation in the particular circumstance is not necessary to achieve its underlying purpose.
The purpose of 10 CFR 50, Appendix J is to assure that leakage through the primary reactor containment and systems and components penetrating primary containment shall not exceed allowable leakage rate values as specified in TS.
The majority of CILRT failures are directly attributed to leakage from i
containment penetrations and identified by LLRT programs.
Therefore, it may be concluded that deferring the CILRT for one outage will have no significant effect on achieving the underlying purpose of the rule.
l Backcround The Callaway containment system is designed to control the release of airborne radioactivity following postulated design basis accidents and to provide shielding for the reactor core and reactor coolant system.
The containment system consists of a prestressed, reinforced concrete, cylindrical structure with a hemispherical dome.
The cylinder and dome are reinforced by bonded reinforcing steel.
The interior of the containment is lined with 1/4 in. thick carbon steel plates welded together to form a barrier which is essentially leak tight.
The liner is
[
thickened locally around penetrations, large brackets, and
Attachmsnt 3 Page 2 of 6 major attachments and is anchored to the concrete structure.
The integrity and capability of the containment to perform its intended function is demonstrated by the performance of periodic testing.
CILRTs are defined in 10 CFR 50, Appendix J, Section II.F as those tests intended to measure the imary reactor containment overall integrated leak,3 rate at periodic v
intervals.
The time required to par #orm the CILRTs necessitates'that they be performed during refueling outages.
The major safety benefits achieved by performance of the CILRT is the detection of leakage not identified by an LLRT and the detection of gross containment failure, which is a low probability event.
Prior to the performance of the CILRT, a general visual inspection of all accessible interior surfaces of the steel liner plate and exterior surfaces of the containment concrete wall is conducted.
This inspection is performed in accordance with TS Surveillance Requirement 4.6.1.6.3 and approved plant procedures.
The purpose of the inspections is to detect any evidence of structural deterioration (corrosion or deformation of the steel liner and spalling and cracking of the concrete) which may affect the containment structural integrity or its leaktightness.
The inspections conducted in support of each of the periodic CILRTs have identified no evidence of structural l
deterioration that would impact structural or leak tightness
)
of containment.
Therefore, absent actual accident
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conditions, structural deterioration is a gradual phenomenon U
requiring periods of time well in excess of the proposed interval extension.
Data from the first and second CILRT illustrates that the as-found and as-left leakage rates were below the acceptance limits established in 10 CFR 50, Appendix J and the TS.
Appendix J and TS require that the as-found leakage rate be less than La (0.20 wt%/ day) and the as-left leakage rate be less than 75% of La (0.15 wt%/ day).
The as-found leakage rates for the first two CILRTs were 0.0556 and 0.1987 wt%/ day.
The as-left leakage rates for the first two CILRTs were 0.044 and 0.0524 wt%/ day.
The majority of the as-found leakage from the first and second CILRT was identified by Type C testing.
The as-found leakage from the second CILRT was attributed to leaking valves in the ESW system during Type C testing.
Replacement of these valves with an improved design resulted in an improvement of 84% in local leakage testing of the affected penetrations.
This information demonstrates that the containment is essentially leak-tight and left with margin for increased leakage conditions between periodic tests.
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Attachmsnt 3 Page 3 of 6 Type B and C tests (Local Leakage Rate Tests or LLRTs) are used to determine leakage rates through systems and components that penetrate containment.
The Callaway LLRT programs are aggressive testing programs that provides good containment assurance.
Each penetration is assigned an administrative limit used for testing purposes.
The limit is based upon a careful review of penetration history and the line size versus the allowable limit.
This limit is used to identify any potential concern for a given penetration and ensures that the containment does not come close to the allowable limit for the LLRT programs.
These tests are currently performed at least every 2 years (and will continue to be performed on this schedule).
Since the LLRT programs are unchanged, assurance that containment integrity is maintained can also be verified by the performance of the LLRTs.
Data from past tests at Callaway Plant and from NEI indicates that the majority of the CILRT failures and near failures are directly attributable to leakage from containment penetrations and not from the containment structure.
These types of failures are found with the LLRT programs.
Consequently, the very small percentage of failures attributed to the containment structure would be identified by the CILRT.
Modifications that would alter the passive containment structure are infrequent and would receive extensive review to ensure containment capabilities are not diminished.
The Callaway modification process and 10 CFR 50.59 programs have i
been demonstrated to be effective in providing a high quality oversight of such safety significant modifications, In addition, 10 CFR 50, Appendix J, Section IV.A requires containment integrated leak rate testing be performed following any major modification to the primary containment boundary.
This requirement will be maintained.
To date, no changes have been made (or are planned prior to Refuel 8) to the containment which would require a CILRT retest.
A benefit of this one-time exemption is to postpone the personnel radiation exposure which would be incurred by performing the CILRT in Refuel 7.
The dose savings for Refuel 7 from the elimination of contamination, the reduction of exposure for venting and draining and from setup and restoration of the instrumentation during and after the test is approximately 2 nanrem.
A second benefit is the saving of approximately $2,000,000 realized by avoided replacement power costs (associated with 3-5 days extended outage time), equipment and labor costs needed to perform the CILRT.
An additional benefit is the elimination of potential human errors in reconfiguring the large number of systems and components that have to be altered to perform a CILRT.
Attachmont 3 Page 4 of 6 Risk Assessment Draft NUREG-1493 includes the results of a sensitivity study performed to explore the risk impact of several alternate leak rate testing schedules.
Alternative 4 from this study examines relaxing the CILRT frequency from 3 tests in 10 years to 1 test in 10 years.
Using best estimate data, the draft NUREG concludes that the increase in, population exposure risk to those in the vicinity of_the five representative plants ranged from 0.02% to 0.14%.
This very low impact on risk is attributable to:
- 1) the effectiveness of LLRTs identifying potential leak paths (only about 3% of leakage that exceeds current requirements is detectable only by CILRTs, and those few failures were only marginally above prescribed limits), 2) a low likelihood of CILRT-identified leakage in excess of 2 times allowable, and 3) the insensitivity of risk to containment leak rate (e.g., no discernible increase in. population dose risk with containment leak rates 100 times greater than currently allowed).
This led the authors of draft NUREG-1493 to conclude that even increasing the CILRT frequency to once in 20 years would lead to a very small increase in risk.
The analyses presented in draft NUREG-1493 are considered to be bounding for callaway because:
- 1) the requested exemption would result in a one-time test interval of about 6 years, not the 20 or even the 10 years mentioned in the study; 2) the population density around callaway is less than that used in the study (approximately 29 people per square mile at ten miles, versus the 340 people per square mile beyond 1/2 mile used in the study); and 3) no CILRT at Callaway has failed.
Evaluation The containment integrated leak rate test interval extension does not involve an unreviewed safety question because operation of Callaway Plant with this change would not:
1.
Increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the Safety Analysis Report.
The callaway CILRT history provides substantial justification for the proposed test schedule.
Three CILRTs have been performed over a seven year period with successful results.
The tests indicate that callaway has a low leakage containment.
There are no structural mechanisms which would adversely affect the structural capability of the containment and that would be a factor in extending the CILRT schedule by one refueling outage.
A risk impact assessment was performed, and a determination was made that there is
4 A
L Page 5 of 6 insignificant risk impact as a result of changing the CILRT schedule.
Containment leak rate testing is'not an initiator of any accident, the proposed interval i
extension does~not affect reactor operations or the accident analysis, and has no radiological consequences.
There will be no changes to 10 CFR 100 1
dose limits or the control room dose limits.
Extending the test interval will not, by itself,: increase the probability of a malfunction of equipment important'to safety.
Therefore, the proposed change will not involve a significant increase in the probability or consequences of any accident previously evaluated.
2.
Create the possibility for an accident or malfunction of equipment of a different type than any previously evaluated in the Safety Analysis Report.
]
There are no design changes being made that would create a new type of accident or malfunction.
The j
proposed change will not alter the plant or the manner in which it is operated.
The change revises the schedule for performing the periodic CILRT.
The purpose of the test is to provide periodic verification of the loaktight integrity of the primary reactor containment, and systems and components which penetrate containnant.
The tests assure that leakage through containment and systems and components penetrating containment will not exceed the allowable leakage rate values associated with conditions resulting from an accident.
The change in schedule for performing the CILRT will not adversely affect the containment integrity in the event of an accident.
Therefore, the proposed change will not create the possibility of a new or different type of accident from any accident previously evaluated.
3.
Reduce the margin of safety as defined in the basis for any technical specification.
The proposed change to the schedule for performing the periodic CILRT does not reduce the margin of safety assumed in the accident analysis for any release of radioactive materials or reduce any margin of safety preserved by the technical specifications.
The methodology, acceptance criteria, and the technical specification leakage limits for the performance of the CILRT will not change.
CILRTs will continue to be performed in accordance with 10 CFR 50, Appendix J and the Callaway Technical Specifications.
Therefore, the proposed change will t involve a reduction in a margin of safety.
f Attachm:nt 3 Page 6 of 6 Conclusion Given the above discussions as well as those presented in the Significant Hazards Consideration, the proposed change does not adversely affect or endanger the health or safety of the general public or involve a significant safety hazard.
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ATTACHMENT 4 SIGNIFICANT HAZARDS EVALUATION I
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s Attachmant 4 Page 1 of 5 SIGNIFICAUT HAZARDS EVALUATION This application requests an exemption to 10 CFR 50, Appendix J, Section III.D.1(a) and a revision to Technical Specification (TS) Surveillance Requirement 4.6.1.2.a and its associated Bases.
10 CFR 50, Appendix J and the Callaway TS require that a set of three Containment Integrated Leak Rate Tests (CILRTs or Type A tests) be performed, at approximately equal intervals during each 10-year service period.
This change consists of an exemption request and TS amendment that would defer the next scheduled CILRT for one outage, from Refuel 7 (scheduled for March 1995) to Refuel 8 (scheduled for September 1996).
The preoperational CILRT was performed in January 1984.
The first and second CILRTs, of the set of three tests for the first ten-year service period, were conducted in April 1987 and October 1990, respectively.
This represents testing intervals of 40 and 41 months.
The third CILRT is required to be performed prior to restart following Refuel 7.
Deferring the third CILRT until Refuel 8 results in a test interval of approximately 72 months.
Exemption Reauest 10 CFR 50.12 states that the NRC may grant exemptions to its regulations in Part 50 if special circumstances exist.
Special circumstances are considered to exist if application of the regulation in the particular circumstance is not necessary to achieve its underlying purpose.
The purpose of 10 CFR 50, Appendix J is to assure that leakage through the primary reactor containment and systems and components penetrating primary containment shall not exceed allowable leakage rate values as specified in TS.
The majority of CILRT failures are directly attributed to leakage from containment penetrations and identified by LLRT programs.
Therefore, it may be concluded that deferring the CILRT for j
one outage will have no significant effect on achieving the
)
underlying purpose of the rule.
Backaround CILRTs are defined in 10 CFR 50, Appendix J, Section II.F as those tests intended to measure the primary reactor containment overall integrated leakage rate at periodic intervals.
The time required to perform the CILRTs necessitates that they be performed during refueling outages.
The major safety benefits achieved by performance of the CILRT is the detection of leakage not identified by an LLRT and the detection of gross containment failure, which is a low probability event.
Attachmsnt 4 Page 2 of 5 Data from the first and second CILRT illustrates that the as-found and as-left leakage rates were below the acceptance limits established in 10 CFR 50, Appendix J and the TS.
Appendix J and TS require that the as-found leakage rate be less than La (0.20 wt%/ day) and the as-left leakage rate be less than 75% of La (0.15 wt%/ day).
The as-found leakage rates for the first two CILRTs were 0.0556 and 0.1987 wt%/ day.
The as-left leakage rates for the first two CILRTs were 0.044 and 0.0524 wt%/ day.
The majority of the as-found I
leakage from the first and second CILRT was identified by Type C testing.
The as-found leakage from the second CILRT was attributed to leaking valves in the ESW system during Type C testing.
Replacement of these valves with an improved design resulted in an improvement of 84% in local leakage testing of the affected penetrations.
This information demonstrates that the containment is essentially leak-tight and left with margin for increased leakage conditions between periodic tests.
Type B and C tests (Local Leakage Rate Tests or LLRTs) are used to determine leakage rates through systems and components that penetrate containment.
The Callaway LLRT programs are aggressive testing programs that provides good containment assurance.
Each penetration is assigned an administrative limit used for testing purposes.
The limit is based upon a careful review of penetration history and the line size versus the allowable limit.
This limit is used to identify any potential concern for a given penetration and ensures that the containment does not come close to the allowable limit for the LLRT programs.
These tests are currently performed at least every 2 years (and will continue to be performed on this schedule).
Since the LLRT programs are unchanged, assurance that containment integrity is maintained can also be verified by the performance of the LLRTs.
1 Data from past tests at Callaway Plant and from NEI indicates that the majority of the CILRT failures and near failures are directly attributable to leakage from containment penetrations and not from the containment structure.
These types of failures are found with the LLRT programs.
Consequently, the very small percentage of failures attributed to the containment structure would be identified by the CILRT.
Modifications that would alter the passive containment structure are infrequent and would receive extensive review to ensure containment capabilities are not diminished.
The Callaway modification process and 10 CFR 50.59 programs have been demonstrated to be effective in providing a high quality oversight of such safety significant modifications, In addition, 10 CFR 50, Appendix J, Section IV.A requires q
containment integrated leak rate testing be performed j
following any major modification to the primary containment l
l
Page 3 of 5 boundary.
This requirement will be maintained.
To date, no changes have been made (or are planned prior to Refuel 8) to the containment which would require a CILRT retest.
Risk Assessmant Draft NUREG-1493 includes the results of a sensitivity study performed to explore the risk impact of several alternate leak rate testing schedules.
Alternative 4 from this study examines relaxing the CILRT frequency from 3 tests in 10 years to 1 test in 10 years.
Using best estimate data, the draft NUREG concludes that the increase in population exposure risk to those in the vicinity of the five representative plants ranged from 0.02% to 0.14%.
This very low impact on risk is attributable to:
- 1) the effectiveness of LLRTs identifying potential leak paths (only about 3% of leakage that exceeds current requirements is detectable only by CILRTs, and those few failures were only marginally above prescribed' limits), 2) a low likelihood of CILRT-identified leakage in excess of 2 times allowable, and 3) the insensitivity of risk to containment leak rate (e.g., no discernible increase in population dose risk with containment leak rates 100 times greater than currently allowed).
This led the authors of draft NUREG-1493 to conclude that even increasing the CILRT frequency to'once in 20 years would lead to a very small increase in risk.
The analyses presented in draft NUREG-1493 are considered to be bounding for Callaway becauve:
- 1) the requented exemption would result in a one-time test interval of about 6 years, not the 20 or even the 10 years mentioned in the study; 2) the population density around-Callaway is less than that used in the study (approximately 29 people per square mile at ten miles, versus the 340 people per square mile beyond 1/2 mile used in the study); and 3) no ILRT at Callaway has failed.
Evaluat12D The Type A test interval extension does not involve a significant hazards consideration because operation of Callaway Plant with this change would not:
1.
Involve a significant increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the Safety Analysis Report.
The Callaway CILRT history provides substantial justification for the proposed test schedule.
Three CILRTs have been performed over a seven year period with successful results.
The tests indicate that Callaway has a low leakage containment.
There are no structural mechanisms which would adversely affect the
Attachmont 4 Page 4 of 5 structural capability of the containment and that would be a factor in extending the CILRT schedule by one H
refueling outage.
A risk impact assessment was performed, and a determination was made that there is insignificant risk impact as a result of ch'.nging the CILRT schedule.
Containment leak rate testing is not an initiator of any accident, the proposed interval extension does not affect reactor operations or the accident analysis, and has no radiological consequences.Thore will be no changes to 10 CFR 100 dose limits or the control room dose limits.
Extending the test interval will not, by itself, increase the probability of a malfunction of equipment important to safety.
Therefore, the proposed change will not involve a significant increase in the probability or consequences of any accident previously evaluated.
2.
Create the possibility of a new or different kind of accident from any previously evaluated in the Safety Analysis Report.
There are no design changes being made that would create a new type of accident or malfunction.
The proposed change will not alter the plant or the manner in which it is operated.
The change revises the schedule for performing the periodic CILRT.
The purpose of the test is to provide periodic verification of the leaktight integrity of the primary reactor containment, and systems and components which penetrate containment.
The tests assure that leakage through containment and systems and components penetrating containment will not exceed the allowable leakage rate values associated with conditions resulting from an i
accident.
The change in schedule for performing the CILRT will not adversely affect the containment integrity in the event c an accident.
Therefore, the proposed change will not create the possibility of a new or different type of accident from any accident previously evaluated.
3.
Involve a significant reduction in a margin of safety.
The proposed change to the schedule for performing the periodic Type A test does not reduce the margin of safety assumed in the accident analysis for any release of radioactive materials or reduce any margin of safety preserved by the technical specifications.
The methodology, acceptance criteria, and the technical specification leakage limits for the performance of the Type A tests will not change.
The Type A tests will continue to be performed in accordance with 10 CFR 50, Appendix J and the Callaway Technical Specifications.
Therefore, the proposed change will not involve a reduction in a margin of safety.
Attachmsnt 4 Page 5 of 5 Conclusion Given the above discussions as well
.a those presented in the Safety Evaluation, the proposed change does not adversely affect or endanger the health or safety of the general public or involve a significant hazards consideration.
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1 ATTACHMENT 5 ENVIRONMENTAL CONSIDERATION i
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Page 1 of 1 ENVIRONMENTAL CONSIDERATION This application requests an exemption to 10 CFR 50, Appendix J,
Section III.D.1(a) and a revision to Technical Specifi-cation (TS) Surveillance Requirement 4.6.1.2.a and its associated Bases.
10 CFR 50, Appendix J and the Callaway TS require that a set of three Containment Integrated Leak Rate Tests (CILRTs or Type A tests) be performed, at approximately equal intervals during each 10-year service period.
This change consists of an exemption request and TS amendment.that would defer the next scheduled CILRT for one outage, from Refuel 7 (scheduled for March 1995) to Refuel 8 (scheduled for September 1996).
The proposed amendment involves changes with respect to the use of facility components located within the restricted area, as defined in 10 CFR 20, and changes surveillance requirements.
Union Electric has determined that the proposed amendment does not involve:
(1)
A significant hazard consideration, as discussed in of this amendment application; (2)
A significant change in the types or significant increase in the amounts of any effluents that may be released offsite; (3)
A significant increase in individual or cumulative occupational radiation exposure.
Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22 (c) (9).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or enviromental assessment need be prepared in connection with the issuance of this amendment.